United States v. $12,204,262.89 UNITED STATES CURRENCY

CourtDistrict Court, S.D. Indiana
DecidedApril 23, 2025
Docket1:24-cv-01383
StatusUnknown

This text of United States v. $12,204,262.89 UNITED STATES CURRENCY (United States v. $12,204,262.89 UNITED STATES CURRENCY) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. $12,204,262.89 UNITED STATES CURRENCY, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) No. 1:24-cv-01383-SEB-MJD ) $12,204,262.89 UNITED STATES CURRENCY, ) ) Defendant. ) ) ) RICHARD W. EATON, ) NIKOLAOS E. MANOUDAKIS, ) ) Claimants. )

ORDER

This matter is before the Court on the following motions: Claimant Manoudakis' Motion to Supplement and for Leave to File Belated Notice of Intention to File Verified Claim, [Dkt. 47]; Claimant Manoudakis' Motion to Amend Answer and Affirmative Defenses, [Dkt. 50]; and Plaintiff's Motion for Limited Stay of Proceedings, [Dkt. 54]. Each motion is resolved below. I. BACKGROUND This is a civil forfeiture action brought by the United States of America against $12,204,262.89 in United States Currency ("the Currency") and certain real property. The USA's claims relate to an alleged fraudulent scheme by companies called Meds to You, LLC, and Meds to You FL, LLC, (collectively "Meds to You"), to bill Medicare for COVID-19 tests that were not requested by the recipients. The USA alleges that the Currency was obtained through this scheme and therefore was obtained "'by means of false or fraudulent pretenses, representations, or promises, transmit[ted] … by means of wire, … in interstate or foreign commerce … for the purpose of executing [a] scheme or artifice[]' to defraud, 18 U.S.C. § 1343," and is "'money or property owned by, or under the custody or control of, any health care benefit program, in connection with the delivery of or payment for health care benefits, items, or services' and was 'obtain[ed], by means of false or fraudulent pretenses, representations, or promises, … to defraud

any health care benefit program[.]' 18 U.S.C. § 1347." [Dkt. 1 at 31.] The Currency was seized by the USA on August 4, 2023, and this case was filed on August 13, 2024. A Notice of Forfeiture Action was published on the website www.forfeiture.gov, which is maintained by the United States Department of Justice, for 30 consecutive days beginning August 16, 2024. See Dkt. 40-2. On August 19, 2024, the USA sent a Personal Notice of Complaint of Forfeiture in Rem ("the Notice") with a copy of the Complaint to six potential claimants to the Currency, including Manoudakis. [Dkt. 44.] The Notice, which contained the caption of this case, stated: Pursuant [to] Rule G(5)(a)(ii) of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, in order to avoid forfeiture of the Defendant Currency and/or Defendant Real Property, any person who asserts an interest in the Defendant Currency and/or Defendant Real Property must file a verified claim within thirty-five (35) days after the date of the mailing of this notice, which is September 23, 2024.

Id. at 2 (emphasis in original). It further provided: Pursuant to Rule G(5)(a), the claim must (A) identify the specific property claimed; (B) identify the claimant and state the claimant's interest in the property; and (C) be signed by the claimant under penalty of perjury, see 28 U.S.C. § 1746.

Id. It further provided that if a verified claim was filed, the claimant must then file a response to the Complaint in this case within 21 days of filing the verified claim, and that both the verified claim and the response were to be filed in this case and served on the USA. The Notice concluded with the warning that "[f]ailure to file a claim and an answer within the specified times will result in default judgment pursuant to Rule 55 of the Federal Rules of Civil Procedure." Id. at 3. The Notice was delivered to Manoudakis' address via certified mail on August 24, 2024. [Dkt. 54 at 3.] On September 20, 2024, Manoudakis, who was then acting pro se, filed a motion

for a 28-day extension of time to respond to the Complaint. [Dkt. 6.] That motion was granted, and Manoudakis' deadline to response to the Complaint was extended to October 22, 2024. [Dkt. 7.] Counsel appeared on behalf of Manoudakis on October 9, 2024; his counsel obtained two additional enlargements of time to respond to the Complaint, ultimately resulting in a deadline of November 22, 2024. [Dkt. 12, Dkt. 23.] Manoudakis filed an Answer to the Complaint on that date. [Dkt. 26.] While the Answer contains a verification section, it is not signed by Manoudakis and therefore is not verified. Manoudakis did not file, and has not to date filed, a verified claim. On November 26, 2024, the Court entered a Case Management Plan in this case that set a deadline of February 7, 2025, for motions for leave to amend pleadings. [Dkt. 29 at 3.]

The USA and another claimant, Richard Eaton, reported on January 29, 2025, that they had resolved Eaton's claim with regard to the real property. [Dkt. 39.] That left Manoudakis' claim with regard to the Currency as the only claim remaining in the case. On February 21, 2025, the USA sought to resolve that claim by filing a Motion to Strike Nikolaos Manoudakis' Answer to Complaint, and Application for Default Judgment and Order of Forfeiture. [Dkt. 45.] The basis of the USA's motion was that Manoudakis had not filed a verified claim as required by 18 U.S.C. § 983(a)(4)(A) and Supplemental Rule for Admiralty or Maritime Claims and Asset Forfeiture Actions G(5)(a) and therefore he lacked statutory standing to pursue his claim for the Currency.1 The USA also argued that Manoudakis lacked constitutional standing to pursue his claim as to some of the Currency because it was seized from accounts that were not held by Manoudakis. In response to this motion, Manoudakis filed his Motion to Supplement and for Leave to File Belated Notice of Intention to File Verified Claim, [Dkt. 47], on February 26, 2025.

Manoudakis also filed a Motion to Amend Answer and Affirmative Defenses, [Dkt. 50], on March 7, 2025, seeking to assert a statute of limitations defense and the defense of failure to state a claim upon which relief may be granted. II. DISCUSSION

Each of the motions before the Court are addressed, in turn, below.

A. Motion to Supplement [Dkt. 47] In his Motion to Supplement and for Leave to File Belated Notice of Intention to File Verified Claim, [Dkt. 47], Manoudakis seeks to remedy his failure to file a timely verified claim. 1. The Applicable Deadline for Manoudakis' Claim Civil forfeiture actions such as this one are governed by both a Rule—Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions Rule G ("Rule G")—and a statute—18 U.S.C. § 983. As relevant to the instant motions, 18 U.S.C. § 983(a)(4)(A) provides: In any case in which the Government files in the appropriate United States district court a complaint for forfeiture of property, any person claiming an interest in the seized property may file a claim asserting such person's interest in the property in the manner set forth in the Supplemental Rules for Certain Admiralty and Maritime Claims, except that such claim may be filed not later than 30 days after

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United States v. $12,204,262.89 UNITED STATES CURRENCY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-1220426289-united-states-currency-insd-2025.